05/19/2026
Hi Neighbours,
We need your help this week. On Wednesday, Town of Comox Council will vote on a comprehensive rezoning RZ25-5 that would permanently lock in a specific development plan for a sensitive coastal property at 721 Lazo Road, before key technical reports have been made public, before a viable alternative has been assessed, and without the public hearing this decision deserves.
Two things you can do right now:
• Email council before Wednesday at [email protected] and ask them to defer RZ 25-5 until all the information is on the table
• Show up Wednesday May 20 at 5:00 pm, Council Chambers, 1809 Beaufort Avenue, Comox. Numbers send a message — just like Brooklyn Creek did
If you can, drive to the end of Andrew Avenue in Point Holmes before Wednesday and see the site for yourself. The steep forested bluff at the end of the lane, shown in the photos attached, is where the new road and three of the six proposed lots would be built. It takes five minutes and is worth seeing in person.
What is being proposed:
RZ 25-5 would rezone 721 Lazo Road from its current Cape Lazo Residential zoning to a new Comprehensive Development zone, enabling a six-lot waterfront subdivision with up to 12 units on individual septic systems, outside the Town's Urban Containment Boundary. A new road would be cut through the forested coastal bluff at the end of Andrew Avenue, a narrow CVRD dead-end lane, to reach the lots.
The proposal includes dedicating about 57% of the property as parkland, with a trail from Lazo Road to the beach. Our neighbourhood genuinely supports that goal. But the staff report presents this as the only way to protect the land - framing it as a necessary choice between the forested bluff at the end of Andrew Avenue and the trees along Lazo Road. We don't think Council has to choose.
The current zoning allows a maximum of four lots, not six. The forested Lazo frontage is already protected by existing OCP zoning and Development Permit Areas. The only imminent threat to the ecological values on this property is this development itself. An alternative plan, prepared by an experienced local developer and sent to town planning and every member of Council weeks ago, proposes the same number of lots clustered on the less sensitive portion of the property, uses the existing Lazo Road access, protects the bluff intact, and still achieves a larger connected park running continuously from Lazo to the ocean. The staff report does not mention this alternative once.
Why the sequencing is backwards - and why it matters:
The most serious concern is this. Council is being asked to approve a Comprehensive Development zone, a site-specific bylaw that permanently locks in this exact development configuration. Once readings 1 through 3 pass on Wednesday, this layout is enshrined. There is no easy path back. And Council is being asked to do this before:
• the geotechnical report has been made public
• the floodplain analysis has been made public
• the septic feasibility study has been made public
• the Pacificus environmental report has been provided for public viewing - only a partial aerial map has been shared, which neighbours and local experts say significantly underrepresents the ecological values on site, including Garry oak stands and eagle perch trees visible from the street
• any agency has assessed Andrew Avenue's physical capacity to serve a subdivision — no one has done this
This property has been refused subdivision before. The land hasn't changed. What has changed is the legislative environment created by Bill 44, a tool designed to address the housing crisis in serviced urban areas, not to unlock subdivisions on unserviced coastal properties outside the Urban Containment Boundary that have previously been refused on exactly these grounds.
A few other things worth knowing:
There is no public hearing. Staff have invoked Bill 44 to bypass one, claiming this rezoning is consistent with the OCP. The staff report itself acknowledges conflicts with OCP policies on parcel size, servicing, and road access. Whether that finding holds up legally is an open question that hasn't been answered.
The bluff is part of the Cape Lazo Coastal Sand Ecosystem, one of only two remaining wind-blown dune complexes in the Georgia Basin, supporting four provincially red-listed ecological communities. The Garry oaks on the dune face may be well over 100 years old. Once cleared, they cannot be restored.
Independent arborist and engineering reports commissioned by adjacent property owners identify windthrow, drainage, slope instability, and well interference risks to neighbouring CVRD properties risks the applicant's professionals were apparently never asked to consider, and that would fall entirely on residents who have no vote in this jurisdiction.
Like Brooklyn Creek, a pattern worth noticing:
This application follows a pattern Comox residents have seen before - OCP and DPA conflicts minimized in the staff report, agency support overstated, community concerns deferred to later stages. Council recently held the line on the Cedar Avenue OCP amendment and was praised for doing so. The new OCP exists for a reason. The Development Permit Areas exist for a reason. We are asking for the same standard to be applied here.
We are not asking Council to say no to development on this property. We are asking them to slow down and get it right before something irreversible is locked in. A better outcome is possible. One that achieves the park, protects the bluff, and still allows the owners to develop.
Please forward this to anyone who cares about responsible development and the protection of Comox Valley ecosystems. And please come out on Wednesday! Your presence matters.
Thanks for your support,
Radford Beach Neighbourhood Association
Photos attached: the forested bluff from the beach at low tide, showing the last intact coastal dune in this stretch of Cape Lazo shoreline; and the end of Andrew Avenue showing the narrow road and rezoning notice at the point where the new access would begin.
